phwun Privacy Policy

1. Introduction

phwun ("phwun," "we," "us," or "our") operates the online gaming platform accessible at phwun.com (the "Platform"). We are committed to protecting the privacy and personal data of all players, visitors, and users ("you" or "your") who interact with the phwun Platform.

This Privacy Policy describes the types of personal data phwun collects, the purposes for which that data is used, the parties with whom it may be shared, and the rights available to you as a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its implementing rules and regulations.

By registering an account on phwun, accessing the Platform, or otherwise providing your personal data to phwun, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, please do not use the phwun Platform.

This Privacy Policy should be read together with phwun's Terms and Conditions, which are available at phwun.com/terms-conditions.

2. Personal Data We Collect

phwun collects the following categories of personal data from players and Platform visitors:

phwun does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive data is collected (such as government ID numbers), it is handled with the highest level of security and access controls.

3. How We Collect Your Data

phwun collects personal data through the following means:

• Direct interactions: Data you provide when registering your phwun account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the phwun Platform, including through cookies, web beacons, pixel tags, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering screening services; payment data from GCash, PayMaya, and banking partners.
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with licensing, compliance, or investigation requirements.

4. How We Use Your Personal Data

phwun uses your personal data for the following purposes:

• To create, verify, and manage your phwun account
• To process deposits, withdrawals, and other financial transactions in Philippine Peso
• To verify your identity and age (21+) in compliance with PAGCOR regulations and the DPA
• To provide customer support and respond to your inquiries
• To detect, prevent, and investigate fraud, money laundering, and other illegal activities
• To personalize your phwun experience and recommend relevant games and promotions
• To send you transactional communications (account notifications, withdrawal confirmations, security alerts)
• To send you marketing communications, where you have provided consent or where permitted by applicable law
• To monitor and enforce responsible gaming limits and self-exclusion orders
• To analyze Platform usage and improve phwun's products and services
• To comply with legal obligations under Philippine law, including PAGCOR reporting requirements and anti-money laundering regulations

phwun will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5. Legal Basis for Processing

phwun processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and phwun (i.e., to operate your account, process transactions, and provide gaming services).
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, anti-money laundering laws, and tax reporting obligations.
• Legitimate interests: Processing necessary for phwun's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

phwun does not sell, rent, or trade your personal data to third parties for their own marketing purposes. phwun may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML screening services used to verify player identity and comply with regulatory requirements.
• Game providers: Software providers such as PG Soft, Jili, Pragmatic Play, and Evolution Gaming, who may receive limited technical data necessary to deliver their games on the phwun Platform.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where disclosure is required by law or regulation.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors who process data on phwun's behalf under strict data processing agreements.
• Professional advisers: Lawyers, auditors, and accountants, where necessary for legal, compliance, or financial purposes.

All third parties with whom phwun shares personal data are required to maintain appropriate security measures and to process data only in accordance with phwun's instructions and applicable Philippine law.

7. Cookies & Tracking Technologies

phwun uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled without affecting core functionality such as login sessions and security features.
• Performance cookies: Collect anonymized data about how players use the phwun Platform, helping phwun identify areas for improvement.
• Functional cookies: Remember your preferences (such as language settings and responsible gaming limits) to provide a more personalized experience.
• Analytics cookies: Used to understand aggregate player behavior and Platform performance. Data collected is anonymized and not linked to individual players.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the phwun Platform. phwun does not use third-party advertising cookies or behavioral tracking cookies for cross-site advertising purposes.

8. Data Security

phwun implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the phwun Platform
• AES-256 encryption for sensitive data stored in phwun's databases
• Two-factor authentication (2FA) available for all phwun accounts
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security audits, penetration testing, and vulnerability assessments
• 24/7 intrusion detection and monitoring systems
• Secure, geographically redundant data storage facilities

Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, phwun will notify you and the National Privacy Commission in accordance with the requirements of the DPA and its implementing rules.

9. Data Retention

phwun retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention guidelines:

• Account data: Retained for the duration of your phwun account and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine anti-money laundering regulations.
• KYC and identity verification documents: Retained for five (5) years following account closure or the completion of the relevant transaction.
• Support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and usage data: Retained for up to twelve (12) months in identifiable form, after which it may be anonymized and retained for analytical purposes.

When personal data is no longer required, phwun will securely delete or anonymize it in accordance with industry best practices and applicable Philippine law.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by phwun:

• Right to be informed: The right to be informed of how your personal data is collected, used, and processed by phwun.
• Right of access: The right to obtain a copy of the personal data phwun holds about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to phwun's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phwun has violated your data privacy rights.

To exercise any of these rights, please contact the phwun Data Protection Officer at [email protected]. phwun will respond to all data subject requests within thirty (30) days of receipt, in accordance with the DPA's implementing rules.

Please note that certain rights may be limited where phwun is required to retain or process your data to comply with legal obligations, including PAGCOR regulatory requirements and anti-money laundering laws.

11. Children's Privacy

The phwun Platform is strictly intended for persons aged 21 years and above. phwun does not knowingly collect personal data from individuals under the age of 21. If phwun becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended and the data will be deleted in accordance with applicable law.

If you are a parent or guardian and believe that your child has provided personal data to phwun, please contact phwun support immediately at [email protected].

12. International Data Transfers

phwun's primary operations and data storage are based in the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, including game software providers and cloud infrastructure partners.

Where personal data is transferred outside the Philippines, phwun ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to process data in accordance with standards equivalent to those required by the Philippine DPA . phwun will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without your explicit consent or a lawful basis under the DPA.

13. Third-Party Links

The phwun Platform may contain links to third-party websites or services for informational purposes. phwun is not responsible for the privacy practices or content of any third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to data collected by phwun through the phwun Platform.

14. Updates to This Privacy Policy

phwun reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, phwun will notify registered players via email or a prominent notice on the Platform. The "Last updated" date at the top of this page will be revised accordingly.

Your continued use of the phwun Platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated policy, you must cease using the Platform and may request account closure.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or phwun's data processing practices, please contact the phwun Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the phwun Platform
• Postal: phwun Data Protection Officer, Manila, Philippines

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. phwun takes all privacy complaints seriously and will work with you to resolve any concerns promptly.

For responsible gaming concerns, please visit our Responsible Gaming page. For full platform terms, see our Terms & Conditions.